Page 1 of 2 1 2
Thread Options
#2157601 - 12/18/17 09:02 PM CRA Public File change in 2018?
StormFront Offline
Junior Member
Joined: Nov 2016
Posts: 36
Did I read somewhere that public file contents are changing for 2018?

Return to Top
CRA
#2157642 - 12/19/17 03:02 AM Re: CRA Public File change in 2018? StormFront
Reads Regs Online
Diamond Poster
Joined: Nov 2004
Posts: 2,292
Here's the new text of the OCC's CRA rule effective 1/1/18. https://www.ecfr.gov/cgi-bin/text-idx?SI...e=20171124y1.11

If you are subject to HMDA reporting, you will no longer have to have two years of HMDA disclosure statements in your CRA public file. You will need to include in your CRA public file the new HMDA notice which refers the public to the CFPB website to get the HMDA data.
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

Return to Top
#2157679 - 12/19/17 02:53 PM Re: CRA Public File change in 2018? StormFront
RR Jen Offline
Power Poster
RR Jen
Joined: May 2003
Posts: 3,759
Running and riding everywhere ...
https://www.bankersonline.com/regulations/12-228-043

It's also in the Reg's section of BOL.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!

Return to Top
#2157745 - 12/19/17 06:41 PM Re: CRA Public File change in 2018? RR Jen
StormFront Offline
Junior Member
Joined: Nov 2016
Posts: 36
OP here: We become an ISB on Jan. 1, 2018. Does anything else change as far as the Public File goes when graduating from a small to an intermediate-small bank? Regulator is the FDIC. Thank you.

Return to Top
#2157753 - 12/19/17 07:24 PM Re: CRA Public File change in 2018? StormFront
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,612
For the public file, no. An intermediate small bank (ISB) is still a small bank by definition, so the public files rules are the same for an ISB and those that are not and ISB.

The FDIC rules regarding the public file can be found in section 345.43 here: https://www.fdic.gov/regulations/laws/rules/2000-6500.html#fdic2000part345.12
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2157755 - 12/19/17 07:36 PM Re: CRA Public File change in 2018? StormFront
bigfish Offline
Member
Joined: Oct 2006
Posts: 66
trolling for the big one
Do not be too quick to remove the HMDA Disclosure Statements from your CRA Public File.

"Nevertheless, a financial institution must maintain in its public file the HMDA disclosure statements required by the CRA regulations that are not available on the Bureau’s website and, therefore, should not remove HMDA disclosure statements from their CRA public files if that information is not available on the Bureau’s website.”

Return to Top
#2157789 - 12/19/17 08:40 PM Re: CRA Public File change in 2018? StormFront
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 497
We fall under the HMDA threshold to report HELOC's. Will we need to collect GMI on those for CRA purposes?
Thank you!

Return to Top
#2157793 - 12/19/17 08:51 PM Re: CRA Public File change in 2018? bigfish
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 764
Originally Posted By bigfish
Do not be too quick to remove the HMDA Disclosure Statements from your CRA Public File.

"Nevertheless, a financial institution must maintain in its public file the HMDA disclosure statements required by the CRA regulations that are not available on the Bureau’s website and, therefore, should not remove HMDA disclosure statements from their CRA public files if that information is not available on the Bureau’s website.”


When I looked at the CFPB site, they had data going back to 2006. https://www.consumerfinance.gov/data-research/hmda/

Return to Top
#2157876 - 12/20/17 04:00 PM Re: CRA Public File change in 2018? StormFront
RR Jen Offline
Power Poster
RR Jen
Joined: May 2003
Posts: 3,759
Running and riding everywhere ...
Yep, ours is there.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!

Return to Top
#2157878 - 12/20/17 04:08 PM Re: CRA Public File change in 2018? StormFront
Sunshine Lady Offline
Platinum Poster
Sunshine Lady
Joined: Apr 2014
Posts: 620
I am new to looking for this information, but when I go into the tool, I can see it by county. How do I get to my bank to see what information is there? Any information would be appreciated because I am revamping my CRA Public file. Thanks,
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

Return to Top
#2157890 - 12/20/17 04:34 PM Re: CRA Public File change in 2018? StormFront
RR Jen Offline
Power Poster
RR Jen
Joined: May 2003
Posts: 3,759
Running and riding everywhere ...
From the link above:

Get The Data
Filter the Data
Select your year
then choose All Records (for example) in Select suggested filters.
scroll down to Lender and enter your lender ID (click the FFIEC link if you don't know it)
scroll down and click Create Summary Table

From there you can choose more variables or download raw data.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!

Return to Top
#2157894 - 12/20/17 04:37 PM Re: CRA Public File change in 2018? StormFront
Sunshine Lady Offline
Platinum Poster
Sunshine Lady
Joined: Apr 2014
Posts: 620
I figured it out. Thanks,
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

Return to Top
#2157895 - 12/20/17 04:40 PM Re: CRA Public File change in 2018? StormFront
Sunshine Lady Offline
Platinum Poster
Sunshine Lady
Joined: Apr 2014
Posts: 620
Thank you RR Jen.
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

Return to Top
#2158919 - 01/02/18 07:37 PM Re: CRA Public File change in 2018? StormFront
cowgirlsrule Offline
100 Club
Joined: Jul 2014
Posts: 194
Arkansas
Do you put the Lobby Notice in the CRA Public file or the Notice that you give to a requestor?

Return to Top
#2158982 - 01/03/18 02:14 PM Re: CRA Public File change in 2018? StormFront
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 764
cowgirlsrule - If I am reading your post correctly, the Lobby Notice is posted in the lobby of the main office and each branch location. The notice tells the public how and where they can obtain information about the bank's performance under the CRA. I'm not familiar with a "Notice" that is given to the requestor.

Return to Top
#2158988 - 01/03/18 02:35 PM Re: CRA Public File change in 2018? StormFront
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,612
Cowgirl is referring to the new HMDA requirement that a bank both have a posted notice [1003.5(e)] as well as a notice a requesting customer can walk out with [1003.5(b)(2)]. This only applies to HMDA reporters.

As the new 228.43(b)(2) is replacing the requirement to have a copy of your disclosure statement in the public file, it appears to me that you would provide the notice under 1003.5(b)(2) which replaces the availability of the disclosure statement and is the notice the customer can walk out with.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2203055 - 01/15/19 08:11 PM Re: CRA Public File change in 2018? StormFront
In It Together Offline
New Poster
Joined: Feb 2016
Posts: 16
Can the entire CRA Public File be put on the Bank's Website or do we still need something in the Main Office and branches?

Return to Top
#2203058 - 01/15/19 08:37 PM Re: CRA Public File change in 2018? StormFront
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,612
Great question. Fortunately, there is nothing that prohibits your CRA public filing from being stored electronically - as long as it can be accessed by staff when needed. In fact, many banks have done this for years. However, most do it through an intranet or shared drive, rather than through their public website.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2203061 - 01/15/19 08:48 PM Re: CRA Public File change in 2018? Adam Witmer
In It Together Offline
New Poster
Joined: Feb 2016
Posts: 16
I was referring to the Public File, not to the CRA Loan Register. I don't think the Public File can only be posted on the Website and was hoping I was wrong. smile

Return to Top
#2203067 - 01/15/19 09:33 PM Re: CRA Public File change in 2018? StormFront
Darth HMDA, CRCM, CAMS Offline
Diamond Poster
Darth HMDA, CRCM, CAMS
Joined: Dec 2013
Posts: 1,385
CA
At my previous institution we went entirely electronic for the public file and the regulators loved it. We went through 2 exams with the online public file without issue.

A lot of banks have moved in this direction and i have never heard anything negative.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

Return to Top
#2203089 - 01/16/19 12:49 PM Re: CRA Public File change in 2018? In It Together
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,612
Originally Posted By In It Together
I was referring to the Public File, not to the CRA Loan Register. I don't think the Public File can only be posted on the Website and was hoping I was wrong. smile


I was referring to the public file as well. Honestly, I have never heard of a bank placing the public file on their website, though I don't know that this would be a problem since it is supposed to be public anyway. That said, I personally wouldn't want it on my website as that is unnecessary and could (hypothetically) lead to other potential concerns (such as complaints from trade groups). Basically, its not required to be that readily accessible, so why would you go there?

That said, and as Darth HMDA mentioned, many financial institutions store it electronically. I've have advocated storing the public file electronically for years as it is much easier to manage one digital file than it is to manage separate paper files for every one of your branches. There are a few logistics to work out with an electronic public file, but its really nothing more than deciding where/how to store the file electronically and then appropriately training your staff where/how to access the file.

Also, keep in mind that you can't just direct customers to a public file on your website - it has to be available "for inspection upon request" at each branch (as applicable). This means that, even if you have it on your website, you still need a way for customers requesting the file to "inspect" the file. This is usually done by printing a copy of the public file.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2203104 - 01/16/19 03:16 PM Re: CRA Public File change in 2018? Adam Witmer
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 764
Originally Posted By Adam Witmer
Originally Posted By In It Together
I was referring to the Public File, not to the CRA Loan Register. I don't think the Public File can only be posted on the Website and was hoping I was wrong. smile


Honestly, I have never heard of a bank placing the public file on their website, though I don't know that this would be a problem since it is supposed to be public anyway.


There are many financial institutions that have their Public File on their website. SunTrust, First Tennessee, First National Bank of Omaha and US Bank all come to mind.

Return to Top
#2203120 - 01/16/19 04:20 PM Re: CRA Public File change in 2018? StormFront
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,557
Cape Cod
That does not eliminate the requirement that the bank provide a copy of the public file on request either on paper or in another form acceptable to the person making the request. 12 CFR 228.43(d).

Way back in the dark ages, we had our CRA public files on our intranet in Lotus Notes (that shows you how long ago it was). We could print from it at any office, but the only person who ever asked for a copy was an examiner. Once.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2209546 - 03/26/19 05:10 PM Re: CRA Public File change in 2018? RR Jen
ccman Offline
Platinum Poster
Joined: Sep 2007
Posts: 906
I've tried pulling this info from the CFPB website and get no files? We're an FDIC bank, small HMDA reporter.

The files are there on the FFIEC website, but not the CFPB? Confusing, if the data is not on the CFPB website.

Any suggestions?

Return to Top
#2209562 - 03/26/19 06:19 PM Re: CRA Public File change in 2018? StormFront
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,649
Galveston, TX
What are you trying to pull? Public files? They are not maintained outside of the individual banks.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
Page 1 of 2 1 2